CARB II Emission Regulations
The California Air Resources Board (CARB) passed the Airborne Toxic Control Measure (ATCM) in 2007 to limit the amount of formaldehyde emissions permitted in composite wood products. The guidelines cover hardwood plywood with veneer cores (HWPW-VC), hardwood plywood with composite cores (HWPW-CC), particleboard (PB), medium density fiberboard (MDF) and thin MDF (tMDF) and apply to panel manufacturers, distributers, importers, fabricators, and retailers of the covered composite wood products, and finished good containing said products, which are sold to customers in California. The standards were released in two phases, with final emission limits in place as of July 2012, as outlined below.
Any company that is “CARB II” or “CARB” compliant meets the July 2012 standards. The CARB ATCM rules require CARB compliant products to be labeled as such, either on the products or the packaging for finish goods. All Echelon Cabinetry packaging labels carry a notification that the product provided is “California 93120 Compliant for Formaldehyde Phase II”, in accordance with ATCM regulations.
CARB v. NAUF v. NAF v. ULEF
In addition to the CARB standards outlined in the above table, the ATCM also provided special provisions for NAF and ULEF suppliers of hardwood plywood, particleboard, and medium density fiberboard. NAF based resins are “formulated with no added formaldehyde as part of the resin cross linking structure, and include resins made from soy, polyvinyl acetate, or methylene diisocyanate,” while ULEF resins are “formaldehyde containing resins formulated such that the formaldehyde emissions from composite wood products are consistently below applicable Phase 2 emission standards.”[ii]
ATCM sections 93120.3(c) and 93120.3(d) set forth guidelines for NAF and ULEF compliant products. Products that meet the required emissions levels and the ATCM third party certification requirements can apply for an exemption from CARB ATCM regulations.
No-Added Formaldehyde (NAF) Products
The product must be tested and certified by a CARB approved third party certifier and must include three months of routine quality control testing data, among other testing requirements. “Ninety percent of the three months of routine quality control testing data and the results of the one primary or secondary method test must be shown to be no higher than 0.04 ppm. In addition, all data must be shown to be no higher than 0.05 ppm for HWPW and 0.06 ppm for PB, MDF, and thin MDF” (ATCM 93120.3(c)).[iii] NAF products are often marketed as “formaldehyde-free.”
Ultra-Low Emitting Formaldehyde (ULEF) Products
Emissions caps for ULEF resin products are outlined in the table below, as provided in ATCM 93120.3(d).[iv]
No Added Urea-Formaldehyde (NAUF) Products
NAUF products do not use urea-formaldehyde resins in the making of the board. Rather, they use phenol formaldehyde as a resin, which is designed to restrict the formaldehyde from off-gassing. CARB ATCM does not address NAUF. LEED v.4 also switches focus from NAUF to CARB NAF and ULEF compliant products.
Regardless of which production method you elect to use on your project, wood itself naturally contains formaldehyde so there will be some amount of formaldehyde in any board, the emissions of which will fall below any emissions regulations.
The EPA’s Stance
When CARB first launched the ATCM standards in 2009, it was the most stringent formaldehyde emissions standards in the US. At the time, there were no national standards in place for formaldehyde in composite wood products. However, in 2010 the Formaldehyde Standards for Composite Wood Products Act, or Title VI of the Toxic Substances Control Act (TSCA) was signed into law. The EPA is currently finalizing rules that will set limits on formaldehyde emissions from composite wood products, both domestic and imported, that are sold or supplied to customers in the United States. The current proposed rules would mirror the limits already in place under CARB ATCM regulations.[v] The most recent update from the EPA indicates final rules is projected to be published in The Federal Register in September, 2015.[vi]
http://www.arb.ca.gov/toxics/compwood/factsheet.pdf (chart and content)
[iv] Ibid (chart and content)